A new article in Forbes says the IRS is planning to “crush” transfer pricing abuse by recruiting “a crack unit of specialists” from Big Four audit firms, boutique consultancy firms, and top law firms. “A number of multinational companies” are in the team’s sights,” says the article. Tops on the list are those in the pharmaceutical and high-tech sectors, the same ones—such as Apple, Microsoft, Oracle, and Pfizer—that are setting up shops overseas in such “garden spots” as Ireland, the Netherlands, and the Caymans.

Most tax professionals tend to think the IRS will have an “uphill battle,” however, given the “billions and billions of dollars” at stake, the article says. The IRS is also still in the midst of a budget and hiring crunch (which may have hampered its efforts to fulfill a similar promise, made just a few years ago—before the economic crisis hit—to ramp up its oversight on 409A abuses). And yet, its recruitment of a transfer pricing “SWAT team” from the top echelons of accounting and law, who may have jumped from the private to the public sector precisely due to the financial crisis, speaks to the IRS’s current levels of committed force. Both sides of any ensuing battles on transfer pricing will require experts, of course, and will likely be looking to recruit from the “top guns” in the BV and IP valuation professions.